Compliance verification activity type: Field Inspection
Team:
Regulated company: Enbridge Pipelines Inc.
Operating company: Enbridge Pipelines Inc.
Province(s) / Territory(s):
Discipline(s):
Related events:
Rationale and scope:
An environmental construction inspection of Enbridge Pipelines Inc. (Enbridge) Line 3 Replacement Project (L3R or L3RP) Spread 7 near Brandon, MB. This inspection was co-conducted by with Indigenous Monitors (IMs) representing the Line 3 Indigenous Advisory and Monitoring Committee (IAMC). The scope of the inspection included but was not limited to biosecurity protocols (to prevent the spread of weeds and soil-borne pathogens), wetland and watercourse mitigation, contaminated sites, sensitive environmental features (e.g. rare plants), heritage resource and traditional land use sites/areas, and incident follow-up. Construction activities observed during the inspection included horizontal directional drilling (HDD) of the Souris River and Black Creek, topsoil stripping and grading, preparation of wetland crossings (ramps and aquadam), a track bore, pipe prep and equipment cleaning. Areas where the above activities and stringing, bending, welding, coating and boring had been completed were also observed.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Daily Inspector Meetings and Document Review
Date & time of visit: 2018-09-25 06:00
Discipline: Environmental Protection
Categories:
Facility:
Observations:
Inspection Team (NEB and IAMC representatives) attended daily construction Inspector Meetings (6:00 am 25, 26 and 27 Sept 2018):
Compliance tool used: No compliance tool used
Observation 2 - SSKP 899+500 - Black Creek HDD (Watercourse MB-WC27 / Wetland MB-128) and mud release (INC2018-129)
Date & time of visit: 2018-09-25 15:00
Prior to onsite observations: Company representatives informed Inspection Team at approximately (~) 6:30 am 25 Sept that a number of terrestrial mud to surface releases (MSRs) occurred during pilot and 30" ream and one occurred in wetland at ~8:30 pm 24 Sept (said they stopped drilling/pumping, contained MSR with sandbags and poly, added sawdust to mud; no visual or olfactory evidence of hydrocarbon contamination in mud but will test prior to land-spreading). At ~12:30 pm 25 Sept, company representatives provided an update to the Inspection Team that a hydrocarbon sheen was observed at the wetland MSR site (MSR occurred through area of historical contamination). IO prompted company to submit incident report to NEB and TSB per NEB Event Reporting Guidelines (reported as INC2018-129). Company also reported release to Manitoba Conservation and Water Stewardship (MCWS).Onsite observations:
Observation 3 - SSKP 907+000 - Souris River HDD (Watercourse MB-WC32)
Date & time of visit: 2018-09-26 09:00
Access
Watercourse crossing
Observation 4 - SSKP 907+000 - Souris River HDD (Watercourse MB-WC32) - Access safety
Discipline: Safety Management
Accessed site via shoo fly (wooden travel mats over CAEPLA carpet), then via ROW to HDD site (wooden travel mats over subsoil):
Observation 5 - General observations
Date & time of visit: 2018-09-26 13:00
Drove roads adjacent to various portions of pipeline construction in course of inspection (intermittent segments between SSKP 808 and 855), as well as limited sections along the ROW to access specific noted locations. General observations included:
Observation 6 - SSKP 809+300 - Fine Cleaning Station
Date & time of visit: 2018-09-26 13:30
Observation 7 - SSKP 813+200 - Banister Boneyard
Date & time of visit: 2018-09-26 14:00
Observation 8 - SSKP 821+185 - Native Prairie / Wetland Crossing (MB-1039-6)
Date & time of visit: 2018-09-26 15:00
Observation 9 - SSKP 825+300 - Railway Bore
Date & time of visit: 2018-09-26 16:00
Observation 10 - SSKP 825+300 - Railway Bore - Safety non-compliance (compressed gas cylinders)
Compliance tool used: Corrected Non-compliance (CNC)
Regulatory requirement:
Relevant section(s):
Company action required:
Safely secure compressed gas cylinders in an upright position, and provide photo documentation to IO.
Due date: 2018-09-26
Date closed: 2018-09-26 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Reason closed: Requirement met
Compliance achieved: Yes
Observation 11 - SSKP 827+335
Date & time of visit: 2018-09-26 16:30
Observation 12 - SSKP 827+335 - Safety non-compliance (fire extinguisher)
Affix monthly inspection tag, complete and document monthly inspection of fire extinguisher, and provide photo documentation to IO.
Due date: 2018-09-28
Date closed: 2018-09-28 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Observation 13 - SSKP 835+300 to SSKP 835+900 - Multiple Features
Date & time of visit: 2018-09-27 09:15
Observation 14 - SSKP 828+500 - Setup and Prep
Date & time of visit: 2018-09-27 11:15
Observation 15 - SSKP 841+550 to ~SSKP 840+800 - Wetland Complex (MB-054) / Spill Clean-up (INC2018-115)
Date & time of visit: 2018-09-27 12:00
Observation 16 - SSKP 849+850 - Fine Cleaning Station
Date & time of visit: 2018-09-27 14:30
Observation 17 - SSKP 848+500 to 900 and SSKP849+700 - Wetland Crossing (MB-071) including Aquadam
Date & time of visit: 2018-09-27 15:15
Observation 18 - SSKP 855+100 - Topsoil Stripping and Grading Operations
Date & time of visit: 2018-09-27 16:30
Identified non-compliances to company plans or procedures are non-compliances either to:
- the condition of an authorization document that requires the implementation of that plan or procedure; or
- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program